Justia Civil Rights Opinion Summaries

Carrie Pueblo brought an action against her former domestic partner, Rachel Haas seeking joint custody and parenting time for a child whom Haas conceived through in vitro fertilization and gave birth to in 2008, during the parties’ relationship. Haas moved for summary judgment, arguing that because the parties had never married and Pueblo had no biological or adoptive relationship to the child, Pueblo lacked standing to sue and also failed to state a claim for which relief could be granted. The trial court granted the motion and dismissed the case without prejudice. After Haas moved for reconsideration, the trial court dismissed the action with prejudice. Pueblo then filed her own motion for reconsideration, arguing that she had standing as a natural parent, despite the lack of genetic connection, following the Court of Appeals decision in LeFever v. Matthews, 336 Mich App 651 (2021), which expanded the definition of “natural parent” to include unmarried women who gave birth as surrogates but shared no genetic connection with the children. Pueblo also argued the trial court order violated her Fourteenth Amendment rights to due process and equal protection, as well as those of the child. Furthermore, Pueblo argued that any dismissal should have been without prejudice. The trial court denied reconsideration, distinguishing LeFever on the ground that Pueblo had not given birth to the child. Pueblo appealed, reasserting her previous arguments and further asserting that the equitable-parent doctrine should extend to the parties’ relationship, which had been solemnized in a civil commitment ceremony when it was not yet legal in Michigan for same-sex partners to marry. The Court of Appeals rejected these arguments and affirmed the trial court. Because Michigan unconstitutionally prohibited same-sex couples from marrying before Obergefell v. Hodges, 576 US 644 (2015), the Michigan Supreme Court narrowly extended the equitable-parent doctrine as "a step toward righting the wrongs done by that unconstitutional prohibition. A person seeking custody who demonstrates by a preponderance of the evidence that the parties would have married before the child’s conception or birth but for Michigan’s unconstitutional marriage ban is entitled to make their case for equitable parenthood to seek custody." The trial court's judgment was reversed and the case remanded for that court to apply the threshold test for standing announced here. View "Pueblo v. Haas" on Justia Law

Plaintiff was repeatedly tased while he was a pretrial detainee at the McLennan County jail in Waco, Texas. Plaintiff insists that he did nothing to warrant the use of force—that he was neither threatening nor resisting the officer who tased him. The principal question on appeal is whether Plaintiff has presented sufficient evidence to defeat summary judgment on his ensuing civil rights claims.   The Fifth Circuit reversed summary judgment on Plaintiff’s excessive force claim against Defendant and remanded that claim to the district court for trial. The court reversed and remanded the district court’s grant of summary judgment on Plaintiff’s policy and practice claims to afford Plaintiff the opportunity to discover evidence relevant to those claims. But the court affirmed the dismissal of Plaintiff’s deliberate indifference claim. The court denied the motion to dismiss the appeal for lack of jurisdiction. The court held that a rational jury could find that Defendant’s decision to tase Plaintiff was not justified by any exigency, in which case Defendant’s qualified immunity defense would not shield him from liability because the court’s precedents clearly establish that resort to force in such circumstances is unconstitutional.   Further, the court wrote that it was inappropriate for the court to then dismiss Plaintiff’s policy and practice claims on the ground that Plaintiff failed to present “adequate summary judgment evidence of any official or unofficial policy,” depriving him of his rights. If a jury finds, as it could, that Defendant tased a non-threatening, compliant inmate, then he is not entitled to qualified immunity. View "Boyd v. McNamara" on Justia Law

Illinois’s Sexually Dangerous Persons Act authorizes the commitment and indefinite detention of individuals who are charged with a crime and found to suffer from a mental disorder "coupled with criminal propensities to the commission of sex offenses.” The Act requires care and treatment for the committed person, "designed to effect recovery.” Once detainees are deemed “no longer dangerous,” the state must discharge them. The Supreme Court held, in 1986, that the Act, on its face, complies with the Due Process Clause, noting the lack of punitive intent, the availability of treatment, and the realistic possibility of release.Every Big Muddy River Program detainee participates in a weekly core therapy group. Only detainees who have acknowledged their prior sexual misconduct participate in offense-specific and didactic groups. Big Muddy does not provide individual therapy. Therapists evaluate detainees semiannually and provide them with copies of their evaluations and treatment plans. Detainees may discuss their evaluations with the therapists only in group therapy, not one-on-one. The state contracts with Wexford to evaluate detainees for release. The plaintiffs alleged that Big Muddy’s treatment program was run in a constitutionally deficient manner.The district court concluded that the disparity between Big Muddy’s treatment program and professional standards amounted to a constitutional violation and issued an injunction, requiring that Big Muddy provide the plaintiffs a minimum of 7.5 hours of core group therapy per week; reinstate inactive groups; and use independent evaluators for discharge evaluations.The Seventh Circuit reversed, acknowledging concern about whether Illinois is complying with its Fourteenth Amendment obligations. Detainees receive minimal treatment, raising serious questions about whether rehabilitation and release are realistically available. The district court, however, issued too broad an injunction under the Prison Litigation Reform Act, 18 U.S.C. 3626(a)(1)(A), which requires the least intrusive means available to correct the constitutional violation. View "Howe v. Hughes" on Justia Law

Almost a decade ago, Huntsville, Plaintiff, a Texas firefighter, had gallbladder surgery. It did not go well, and ever since, Plaintiff has needed medication and treatment for complications. And for years, both the City and its fire department accommodated him. But in 2016, not long after his surgery, the City caught Plaintiff asking a fellow employee for his leftover prescription painkillers. Because such a request violated city policy, Huntsville placed Plaintiff on probation and warned that future violations could lead to his termination. The City placed Plaintiff on administrative leave and investigated. Two weeks later, it fired him. Plaintiff sued, claiming retaliation under the ADA, the Rehabilitation Act, and the ADEA, and discrimination under the ADA. Eventually, and over Plaintiff’s request for a Rule 56(d) continuance, the district court granted summary judgment to the City on all claims. January appealed.   The Fifth Circuit affirmed. The court explained that beyond temporal proximity, Plaintiff produced no evidence that Lunsford’s reasoning concerning his intoxication was false (such that he was not actually intoxicated at the time) or pretextual (such that Plaintiff’s protected activities were the real reason for his firing). The court explained that it has said temporal proximity isn’t enough. Nothing Plaintiff provides “makes the inferential leap to [retaliation] a rational one.” Because he failed to rebut this proffered justification for his termination, summary judgment was proper. View "January v. City of Huntsville" on Justia Law

Plaintiff, for her son A.H., sued Defendant Officer under 42 U.S.C. Section 1983, alleging he used excessive force by not giving a warning while searching with a canine trained to “bite and hold.” Trimble moved for summary judgment. The district court denied qualified immunity on the excessive force claim. Defendant appealed.   The Eighth Circuit affirmed. The court explained that there is no dispute that Defendant did not provide a warning when he deployed Ace or when Ace alerted to fresh human odor during the search. The parties dispute whether A.H. heard the warnings from the other officers. A.H., lying underneath a trailer, testified he did not hear any warnings. The court wrote that assuming the facts most favorably to A.H., he did not hear the other officers’ warnings and did not have the opportunity to surrender. Defendant had fair notice from the court’s precedent that the failure to give a warning and an opportunity to surrender violated clearly established law. View "TonyaMarie Adams v. Nathan Trimble" on Justia Law

Plaintiff contracted to haul freight for CTW Transportation Services. Two weeks later, CTW terminated the contract. On October 7, 2020, Plaintiff filed an administrative complaint against CTW with the Department of Labor, alleging that his contract was terminated in violation of 49 U.S.C. Section 31105(a) for reporting safety violations. The administrative law judge (“ALJ”) ordered discovery to close on May 25 and set trial for July 27. At his deposition on March 30, Plaintiff testified that his attorney had not produced all the documents he had given him. Once in federal court, Plaintiff reasserted his Section 31105(a) retaliation claim. CTW moved to dismiss for lack of jurisdiction. The district court agreed that it lacked jurisdiction.   The Eighth Circuit vacated the dismissal. The court explained that in finding that it lacked jurisdiction, the district court did not find that pre-May 5 conduct alone caused the delay. Instead, it relied almost exclusively on Plaintiff’s conduct after May 5, 2011. For example, Plaintiff’s failure to prepare the case for trial and his “heaping personal insults on the ALJ” all occurred in August and September. Such conduct could not have caused the Secretary’s failure to meet the 210-day deadline. CTW argues that we can still affirm because Plaintiff engaged in bad-faith conduct before May 5. But because the district court did not specifically find that pre-May 5 conduct alone caused the Secretary to miss the deadline, its order dismissing the case must be vacated. View "Avery Wilson v. CTW Transportation Services" on Justia Law

Plaintiffs sued police officers under Sec. 1983 after the officers made warrantless entry into their apartment. The district court granted summary judgment to Plaintiffs and Defendants appealed.On appeal, the Eighth Circuit reversed. While warrantless searches are presumptively unreasonable, there is an exception when officers act with probable cause to believe that a crime has been committed and an objectively reasonable basis to believe that exigent circumstances exist.Here, the officers were dispatched to the scene in response to a report of domestic violence. The report received by the officers explained that the 911 call came from a neighbor who thought “abuse” was occurring and heard a “verbal argument,” “someone being thrown around,” and “yelling and screaming” in the upstairs apartment. The neighbor stated that a woman, her boyfriend, and a child lived in the apartment. This created anm exigency, justifying warrantless entry. View "Benedda Cotten v. Ryan Miller" on Justia Law

Plaintiff received his third citation for Driving While Intoxicated (“DWI”). As a term of his probation, Plaintiff, an alcoholic, was required to attend weekly substance abuse classes. Some of these classes conflicted with shifts that Plaintiff was scheduled to work as an operator at a plant owned by Defendant-Appellee La Grange Acquisitions, L.P. Plaintiff informed his supervisors that he was an alcoholic and that several of the court-ordered substance abuse classes would conflict with his scheduled shifts. When Plaintiff was unable to find coverage for these shifts, La Grange, citing this scheduling conflict, terminated Plaintiff. After exhausting his administrative remedies, Plaintiff sued La Grange under the Americans with Disabilities Act (“ADA”), for intentional discrimination, failure to accommodate, and retaliation. The district court granted summary judgment in favor of La Grange on all three claims. Plaintiff appealed.   The Fifth Circuit affirmed. The court explained that the evidence does not create a triable issue of fact as to whether the given reason for his termination was pretextual, that is, “false or unworthy of credence.” Nothing in the record supports such a finding. There is no dispute that, while La Grange may have been able to do more to find coverage for the shifts Plaintiff needed to miss, La Grange did attempt to coordinate coverage for him and, while partially successful, eventually, these efforts failed. It was only at this point when some of Plaintiff’s shifts were left uncovered, that La Grange dismissed Plaintiff. Given this context, no reasonable jury could find that La Grange’s legitimate, non-discriminatory reason—the shift conflict—for Plaintiff’s suspension and termination was pretext for discrimination. View "Mueck v. La Grange Acquisitions" on Justia Law

In 2020, Reardon unsuccessfully ran for Coles County State’s Attorney against the incumbent, Danley. Reardon brought a 42 U.S.C. 1983 lawsuit against public officials (including Danley), the City of Mattoon, and Coles County, alleging violations of his First, Fourth, and Fourteenth Amendment rights. The Seventh Circuit affirmed the dismissal of the suit.In 2019, Danley and the Mattoon Police Department (MPD) subpoenaed Reardon’s Facebook account information during an investigation into his potential involvement in a perjury/bribery case. A judge denied Reardon’s motion to quash but declined to release the documents until after a probable cause hearing. The Seventh Circuit noted that section 1983 curtails the availability of injunctive relief against judicial officers.Coles County Board Member Metzger removed a Reardon campaign sign from a resident’s lawn weeks before the election, allegedly mistakenly believing the sign was installed without permission. The Board determined that no further action was needed. Reardon did not sufficiently allege that Metzger was “acting under color of state law,” and Coles County is not liable based on the Board’s alleged ratification of Metzger’s conduct.Two weeks before the election, Mattoon Chief of Police Taylor posted a photo of himself (in uniform) with Danley, inside his office, on the official MPD Facebook page with a caption encouraging people to vote for Danley. Reardon failed to provide any authority to support that Taylor or Danley violated the Constitution. View "Reardon v. Danley" on Justia Law

In a challenge to the San Francisco Municipal Transportation Agency’s policy of towing safely and lawfully parked vehicles without a warrant based solely on the accrual of unpaid parking tickets, the Coalition argued that the warrantless tows are unreasonable seizures within the meaning of article I, section 13 of the California Constitution and the Fourth Amendment to the U.S. Constitution. The trial court denied a motion for a writ of mandate and declaratory and injunctive relief.The court of appeal reversed. The challenged warrantless tows are not permissible under the vehicular community caretaking exception to the Fourth Amendment’s warrant requirement. The defendants have not shown that legally parked cars with unpaid parking tickets that present no threat to “public safety and the efficient movement of vehicular traffic” may be towed under that exception. The court rejected an argument that the governmental interest in deterring parking violations and nonpayment of parking fines justifies warrantless tows under the vehicular community caretaking exception. The tows at issue may not be justified by analogy to warrantless property seizures in the forfeiture context. View "Coalition on Homelessness v. City and County of San Francisco" on Justia Law